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In sum, petitioner must establish that the deductions
claimed are ordinary and necessary expenses and further must
substantiate the deductions claimed. See also Hradesky v.
Commissioner, 65 T.C. 87, 89-90 (1975), affd. per curiam 540 F.2d
821 (5th Cir. 1976). Petitioner has failed to do so. Except for
respondent's concessions, respondent's determinations are
sustained.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011